Final FBAR Regulations Offer Some Relief For Plan Sponsors, but Filing Obligations Remain


The Treasury Department has issued final regulations concerning the FBAR filings. Some relief is provided for employee benefit plans and plan sponsors, but a blanket exemption is not provided.

On February 24, 2011, a division of the United States Treasury Department issued final regulations (Final Regulations) concerning the Report of Foreign Bank and Financial Accounts, IRS Form TD-F 90-22.1 (FBAR). Although the Final Regulations provide some relief for employee benefit plans and plan sponsors, they do not provide a blanket exemption for benefit plans. Thus, plan sponsors whose plans have foreign financial accounts should be aware of the upcoming June 30, 2011 filing deadline for 2010 filings.

The following discussion is intended to describe the most significant aspects of the Final Regulations for plan sponsors.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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